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The following is the text of the deposition of Cardinal Bernard Law in Suffolk County Superior Court on Wednesday, May 8, 2002. Law answered questions from the attorney for 86 people who filed civil lawsuits alleging Law was negligent in supervising defrocked priest John Geoghan and failed to prevent him from sexually abusing them as children.

VIDEO OPERATOR: We're now recording and on the record. My name is Wayne Martin. I'm a certified legal video specialist for National Video Reporters, Inc. Our business address is 58 Batterymarch Street, Suite 143, Boston, Massachusetts, 02110. We are here in association with Hennessey Corporation, doing business as Robert H. Lange Company of 50 Congress Street, Boston, Massachusetts, 02109.

Today is May 8, 2002 and the time is 9:17 a.m. This is the deposition of Cardinal Bernard Law in the matter of Francis Leary, Plaintiffs, versus Father John Geoghan, Defendants in Suffolk Superior Court, Civil Action No. 99-0371. The deposition is being taken at the Suffolk Superior Courthouse in Post Office Square at Boston, Massachusetts, on behalf of the plaintiffs. The court reporter is Loretta Hennessey of Hennessey Corporation. At this time counsel will state their appearances and the court reporter will administer the oath.

MR. GORDON: I am Attorney William H. Gordon and I represent Plaintiff Francis Leary and 85 other plaintiffs who have brought claims against Father John J. Geoghan, and his supervisors at the Boston Archdiocese at different times. My office address is 100 State Street, 6th floor, Boston, Massachusetts, at the Law Offices of Mitchell Garabedian. With me today is also Attorney Mitchell Garabedian representing the same plaintiffs. We do not, the only plaintiffs we do not represent are Messrs. Hardigan, Ezdra and Pagliuca.

MR. GARABEDIAN: Good morning.

MR TODD: My name is J. Owen Todd. I appear for the Cardinal, Cardinal Law personally.

MR. ROGERS: My name is Wilson D. Rogers, Jr. I appear for His Eminence Cardinal Law personally and for all of the remaining defendants excepting only Thomas Duane and John Geoghan, and I'm with The Rogers Law Firm at One Union Street, Boston.

MR. ROGERS, III: Wilson Rogers, the Third on behalf of all of the defendants excepting Thomas Duane and John Geoghan.

MR. MARK ROGERS: Mark Rogers on behalf of all defendants except for Thomas Duane and John Geoghan.

MR. O'CONNELL: Tim O'Connell representing Mr. Pagliuca.

MS. JACKSON: Susan Jackson for Thomas Duane.

MR. O'DONNELL: Michael O'Donnell for Joseph Ezdra and Michael Hardigan. My address is 165 Washington Street in Quincy.

MR. MURPHY: Tom Murphy on behalf of Thomas Duane.

MS. TANNENBAUM: Shauna Tannenbaum for the Law Offices of Mitchell Garabedian. We represent the 86 plaintiffs.

MR. GARABEDIAN: With me today I have a victim who is also a plaintiff. His name is Mark Keane.

MR. KEANE: Good morning.

BERNARD F. LAW, Sworn a witness called on behalf of the Plaintiffs, having been duly sworn, was examined and testified as follows:

MR. GORDON: The parties will enter a stipulation that all objections except objections as to form are reserved until time of trial.

Further, all motions to strike are reserved until time of trial. The plaintiffs will agree that the deponent may sign under pains and penalties of perjury without having to have his signature notarized.

And let me state, I know there's going to be an objection that is going to be made generally for First Amendment. Let me state an objection for the record, I'm not sure it will create a problem, but it may. As I understand it from counsel who have identified themselves, there are now two counsel at the table both personally representing Cardinal Law, and I guess I'm a little confused as to who will be making objections on behalf of Cardinal Law because it's not normal to have two lawyers able to do that at a deposition.

MR. ROGERS: Well, first of all, let me take the first issue, the First Amendment. I suggest that we agree that I can have a continuing objection as to the First Amendment. I have raised the First Amendment as a defense and feel the inquiry into the internal workings of the Church is inappropriate. I think it would be a more orderly deposition if we go forward with just an agreement on the record that that objection is reserved and is considered made as to all of the testimony and it will be raised in an appropriate forum. I just think it would make for a more orderly inquiry.

As to the Cardinal, Mr. Todd and myself are co-counsel. I was going to suggest that we take the position that an objection by any lawyer on behalf of a defendant runs to all defendants to avoid the situation where one attorney makes it, then everybody else wakes up and say oh, yes, me, too, and then we have all these people yelling out "objection." I just suggest that anybody makes an objection, it runs to all defendants. Now, that obviates your concern, but I don't, I just think it will all make for a more orderly progression.

MR. GORDON: Let's see how it plays out. I think you may be right. Let's see how it plays out. It's my understanding now that there is a standing objection on First Amendment grounds to the questions at the deposition.

MR. ROGERS: Yes.

MR. GORDON: And our position has been clear before. We think there has been an attempt to over, to make an overbroad interpretation of the First Amendment, we don't think it applies to the scope you do and this is an issue we continue to disagree on and the Court has generally more often than not.

MR. ROGERS, III: But we can agree it's a standing objection.

MR. GORDON: Yes.

DIRECT EXAMINATION BY MR. GORDON:

Q. Would you state your name for the record?

A. Yes. My name is Bernard Francis Law.

Q. And what's your date of birth?

A. November 4, 1931.

Q. And where do you reside?

A. I reside in Brighton, Massachusetts, 2101 Commonwealth Avenue.

Q. And is that the Archdiocese Cardinal's residence?

A. And office, that's right. I live over the store.

Q. Are you, you're a citizen of the United States; is that correct?

A. I am.

Q. Are you a citizen also of the Vatican State?

A. You know, I am. But may I qualify that? I am because I inquired of that this week since the question was raised, and I had never considered it before. The answer that I have is that I am. But I must say that it hasn't been something that I've been conscious of in the past 17 years.

Q. It was something that we had heard raised this week. It didn't come from us, but it is now something that we have some interest in knowing.

You're not a citizen of any other country that you know of?

A. No. I was born in Mexico, and by a change in our own law I believe now I would have the ability of dual citizenship in terms of both countries, but I, as a matter of fact, do not have that.

Q. As I understand it now, you could have citizenship in Mexico, but you --

A. As well as the United States.

Q. Yes?

A. Yes.

Q. Do you know if you have any ambassadorial standing with the Vatican?

A. No, I do not. I have represented the Holy See as a legate for a conference, but that was not ambassadorial standing.

Q. Do you have a summer address?

A. No.

Q. Okay. And your primary residence, then, is the Comm. Ave. address?

A. That's correct.

Q. And you don't have a winter address, winter home?

A. No.

Q. Okay. You graduated high school when?

A. 1949.

Q. And where did you graduate high school?

A. Charlotte Amalie High School in St. Thomas, Virgin Island.

Q. Oh how is that high school name spelled?

A. C-H-A-R-L-O-T-T-E, and then capital A-M-A-L-I-E, High School.

Q. And did you go to college right after graduation from high school?

A. I did.

Q. And where did you go to college?

A. I went to Harvard.

Q. And how many years did you stay at Harvard?

A. Four years.

Q. And did you get a baccalaureate degree?

A. I did, 1953.

Q. And what was your degree in?

A. History.

Q. Did you graduate with honors?

A. No.

Q. Okay. After you graduated from Harvard, what did you do next?

A. I entered the seminary.

Q. Which seminary did you enter?

A. I entered the St. Joseph's Seminary in St. Benedict, Louisiana, and I was there for two years, and then I went, was sent by the Bishop to the Pontifical, P-O-N-T-I-F-I-C-A-L, College, Josephinum, which is Joseph and then I-N-U-M, in Worthington, Ohio, and I was there for six years.

Q. Did you receive any degrees from the seminary?

A. The -- no. I received a second Bachelor's in philosophy, but I had -- it was -- by our system it would be a graduate study, but the seminary didn't give you a degree. You finished the course of theology leading to ordination.

Q. While you were at Harvard, did you meet the late Bishop Lawrence Reilly?

A. I did.

Q. And when you met him, was he a priest or a Bishop?

A. He was a priest.

Q. And it was at the time Father Reilly?

A. Father. Might have been Monsignor, I wouldn't be sure of that. As a matter of fact, I think it was Monsignor.

Q. Did you have discussions with Monsignor Reilly about entering seminary?

A. I did.

Q. Did you keep in touch with Monsignor Reilly after you left seminary?

A. Sporadically.

Q. When you knew Monsignor Reilly, had he served as secretary for Cardinal Cushing at that time, if you know?

A. I -- he was secretary to the Cardinal at one point of my knowing him as chaplain also of Harvard Catholic students.

Q. What year did you become ordained a deacon

A. I was ordained a deacon in 1961.

Q. Do you remember approximately what month?

A. I want to say April.

Q. Spring time?

A. Yes.

Q. Okay. When you were ordained a deacon, how much later was it before your ordination as a priest?

A. I was ordained a priest, May 21, 1961, Pentecost Sunday.

Q. Was there an internship at all while you were a deacon, did you serve any parish doing parish work?

A. As a deacon, no. I -- no.

Q. As a seminarian, did you ever assist in any parishes?

A. Yes.

Q. What did you do as a seminarian in parishes?

A. For six years I worked fully in the summer in parishes, what seminarians do do, helping. I had a pastor who was a wonderful mentor and I went on sick calls, I taught religious education, I tutored, I visited the sick, I did census, I participated in liturgies to the extent that it was appropriate for my status as a seminarian. Assisted in any way I could.

Q. In any of this parish work that you did while in the seminary, was any of it within the confines of the Archdiocese of Boston?

A. No.

Q. What diocese was it in?

A. It was then the diocese of Natches Jackson, Natches-Jackson, which covered the state of Mississippi.

Q. After you were ordained a priest, were you assigned to serve in a parish?

A. I was.

Q. What parish?

A. St. Paul Parish, Vicksburg, Mississippi.

Q. Were you called a curate then or parochial vicar?

A. No, parochial vicar comes later. Curate at that time.

Q. Who was the pastor at St. Paul when you were there?

A. Monsignor Michael J. McCarthy.

Q. How long did you serve as vic -- as curate, excuse me, as curate as St. Paul's?

A. About a year and a half.

Q. After that year and a half, what did you do next?

A. I was named editor of the Diocesean Newspaper, and given a few other jobs as well because it was a small diocese in terms of clergy and number of Catholics. There are only about 40,000 Catholics in the whole state. And I helped out in the parish on weekends where I lived, but it lead into more work than weekends.